Quantifying Escaped Income Mandatory at Reason-Recording Stage: ITAT Delhi

Vijender Nath Gupta Vs ITO (ITAT Delhi) AO reopened the assessment based on information received from the Investigation Wing, which alleged unexplained high-volume transactions in the assessee’s savings account. Major concern was an unsecured loan of ₹8.99 crore from M/s Shiva Chain Pvt. Ltd., a company with very low de-clared income and dubious creditworthiness. Assessee’s claimed all entries were related to inter-firm fund transfers and supported by documen-tation and that the Loan was not interest-bearing and still outstanding. Tribunal’s Findings: Tribunal found serious pro...